Saudi Arabian Monetary Agency

Banking Inspection Department

4133

Anti-Money Laundering and Counter-Terrorism Financing

Rules For Financing Companies
First Update February 2012

TABLE OF CONTENTS

Introduction

Regulatory Framework

Branches and Affiliate Companies

Know Your Customer KYC

Requirements and Ongoing
Customer Due Diligence Measures

KYC

Natural Persons

)a

Legal Persons
Ongoing Customer Due Diligence
Measures

)b

12

13

When Customer Due Diligence is

Required

12

13

Third Parties and mediators

First

Second

Third

Forth

13

14

Complex and Unusual Transactions

13

14

Documents and Records Keeping

14

16

17

16

17

18

15

18

Monitoring Transactions
Reporting of Customers and
Suspicious Transactions
Internal Control Requirements and
Procedures
General Requirements

7
8
First

18

18

Internal Control Procedures

22

20

Cooperation

21

21

Training of Employees

10

22

22

Annex No. 1: ML/TF Indicators

)1

23

23

)2

23

24

)3

24

25

( :)2 ()

26

26

( :)2 ()

27

27

(:)1

Indicators at the beginning of any

financing transaction
Indicators after the beginning of
financing transactions
Indicators about a Companys
Employees
Annex No. 2: Reporting
)Form(Arabic
Annex No. 2: Reporting
)Form(English

Second

)1
)2
)3

INTRODUCTION:

1566/1

1422/7/21

33/ 1424/6/25

Based on the Ministerial Decision No

1566/1 dated 21/7/1420 AH, entrusting
(SAMA) with the power to supervise and
regulate the activity of financial leasing
and financing companies under its
supervision,
Referring to the Anti Money
Laundering Law (AML) and its
Implementing Regulation issued by Royal
Decree No. 39/M dated 25/6/1424 AH and
to the circulars issued by SAMA for
financial leasing companies,
And in compliance with local and
international regulatory and supervisory
requirements for AML/CFT, SAMA has
issued these regulatory rules as compulsory
policies and measures for compliance with
by financing companies licensed by it in
)order to combat Money Laundering (ML
and Terrorism Financing (TF) .

ensuring

()

These rules aim at

compliance of financing companies,
operating in the Kingdom, with AML law
and its Implementing Regulation, helping
financing companies to abide by AML law,
SAMA's rules and all relevant resolutions
issued
by United Nations Security
Council, implementing policies, standards,
measures and laws to prevent, track and
monitor suspicious operations; and
reporting ML and TF activities in
accordance with the Financial Action Task
Force's (FATF) recommendations on
Money Laundering and Financing
Terrorism. The rules also aim at protecting
financing companies operating in the
Kingdom from exploitation for illegal
operations that may involve ML or TF
transactions or any other financial criminal

activity, enhancing and preserving the

confidence of the public in the integrity

and reputation of the financing sector in
the Kingdom and providing the highest
degree of security and safety to customers.

Financing companies, licensed by

SAMA, shall comply with these rules.

/ :

Non-compliance with these rules

shall be considered as a violation of the
terms of the license. Companies shall be
held accountable for the acts of their
employees or negligence to enforce such
rules. Therefore, companies may be subject
to sanctions, including those provided for
in the AML Law. They are also required
to notify SAMA of any impediments that
may prevent compliance with these rules.

1- Regulatory Framework
1. These rules constitute, as a minimum,
basic information required to combat
ML/TF operations.
2. Financing companies shall make these
rules an integral part of their internal
regulations and procedures and they are
required to apply them to all the products
and services they offer, whether directly or
indirectly in cooperation with other
establishments. The companies are also
required to bear in mind the enforcement
of these rules along with the provisions of
the AML Law and its implementing and
other relevant regulations, including the
FATF's recommendations for AML/CFT
and their interpretative notes, in addition to
other rules and circulars issued by SAMA
in this regard.
3. The
ultimate
responsibility
for
4

/ :

implementing these rules lies with the

financing companies which will also be
accountable for the acts committed by their
employees or for their negligence in
implementing these rules. Non-compliance
with these rules shall be considered as a
violation of the license conditions and may
lead to imposing sanctions as provided for
in the AML Law and other relevant
regulations.
4. Financing companies shall inform
SAMA of any difficulties they may
encounter in complying with these rules.

2- Branches and Affiliate Companies

1. The Company is required to ensure that

its branches and affiliates inside and
outside the Kingdom, if any, comply
with these rules, the AML/CFT
regulations and implementation rules
issued in the Kingdom and the FATF's
Recommendations.
2. The Company is required to implement
these rules in its branches and affiliates
outside the Kingdom, if any, within the
limits authorized by the laws and
regulations applicable in the host country.
3. In case of a conflict between the
AML/CFT requirements applicable in the
Kingdom and those in force in the host
countries for the branches or affiliate
companies, the Company shall apply the
higher requirements within the limits
authorized by the laws and regulations
applicable in the host country.
4. In case of a conflict between the host
countrys law and the regulations,
implementation rules and instructions
adopted in the Kingdom, and in case the
branch or affiliate company is unable to
fully comply with the highest
5

requirements,
the
companys
headquarters shall notify SAMA thereof

and comply with any directives that may
be issued in this regard.
5. The Company shall remain in constant
/ contact with SAMA, to be aware of the
latest developments and any weaknesses
:
in the AML regulations applicable in
: :
other countries.
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)3- Know Your Customer (KYC

Requirements and Ongoing CDD
Measures
First Know Your Customer
1.
The Company shall apply the KYC
criteria on all direct and indirect customers
and real beneficiaries (natural or legal
persons).
2.
The Company is prohibited from
engaging in or entering into any financial,
commercial other transactions or any other
operations with an anonymous or fictitious
name or keeping numbered accounts.
3.
The identity and legal status of the
customers and real beneficiaries shall be
verified, based on official documents
effective at the beginning of the
transactions.
4.
The Company is required to update
the aforementioned data on a continuous
basis for all customers, including
customers existing on the issuance date of
these rules. It shall implement Continuous
Customer Due Diligence Procedures on
such data in case of emergence of any
doubts about the accuracy or authenticity
of the information already obtained, at any
stage of dealing with the customer or the
real beneficiary or in case of a suspicion of
the occurrence of an ML or TF operation.
5.
Dealing with any customer shall be
6

terminated in case the Company is unable

to apply the KYC principle, including the
failure to verify his identity or obtain
information about him or the purpose of
the operation. The Company shall consider
submitting its report thereof to the FIU at
the Ministry of Interior.
6.
The customers identities shall be
verified as follows:
a)
Natural Persons:

Saudi Nationals:

Individual Expatriates

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: -
:

:
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National ID Card or Family Record.

Personal address, place of residence
and place of work.

- Contact Numbers.

Residence permits (Iqama) or a 5: -

year Residence Card, passport of the

citizens of the countries of Gulf
Cooperation Council (GCC) or the
diplomatic card for diplomats.

Personal address, place of residence
:
and place of work.
:
b) Legal Persons:
The Company shall obtain sufficient information about the nature of the

business and the customers ownership

structure as well as appropriate specimen signatures of the officials authorized to

manage the customers account, as follows:

Licensed
Companies
and
Establishments:
The Commercial Register issued by the
Ministry of Commerce and Industry.
The license issued by the Ministry of
Municipality and Rural Affairs for
service companies and private stores.
The articles of association and
7

memorandum of association and its

appendices, if any.
The national ID card of the Saudi
citizen, owner of the licensed
commercial or service company, to
verify that his/her name stated in the
commercial register or the licenses
conform with the name and the
information mentioned in the national ID
Card and it is valid.
List of the facilitys owners, whose
names are stated in the articles of
association and the amendments thereof,
if any, and a copy of the ID of each.
List of the persons authorized by the
owner to operate accounts, according to
what is stated in the commercial register
document or by virtue of a power of
attorney issued by the Notary Public or
an authorization prepared within the
Company. A copy of the ID card of each
of the said persons shall also be
obtained.
Resident
Companies
and
Establishments:
- Copy of the commercial register issued by
the Ministry of Commerce and Industry.
- Copy of the Articles of Association and the
annexes thereto.
- Copy of the license to exercise the activity.
- Copy of the ID Card of the manager in
charge.
- A power of attorney Issued by a Notary
Public or a special authorization issued by
the person(s) having the power to authorize
other individuals to sign documents, as per
the Articles of Association.
- Copy of the ID Card of the facilitys
owners whose names are mentioned in the
Articles of Association and the amendments
thereof.
8

: :

Due

Second: Ongoing Customer

Diligence (CDD) Measures:

1. The Company, prior to engaging in

( ) business with a customer, shall cross-
check the customers ID copy against its

original and document the verification
:
and cross-check in writing by the
Companys employee.
-

()
( )%5

2. The Company shall keep a credit record

for all its customers, including all the
data and information about them. This
information shall be documented in
writing, in order to identify all the risks
associated with the customers and
financing operations. In order to avoid
these risks, the file shall include an
appropriate evaluation thereof and an
analysis of the Company and its sector.
The credit file of the customers (natural
or legal persons) shall also include all
related basic information on the customer
and his/her activities, including:
;- The data stated in the credit form
- The Complete data about the customers
;identity
- The transactions performed by the
customer with other establishments, if
;any
- The references to be resorted to in order
to obtain additional information about the
customer, as necessary
- Review of the customer's credit report
obtained from The Saudi Credit
;Information Company (SIMAH), if any
- The names of the owners, and real
beneficiaries, partners and stockholders
;)(holding more than 5% of shares
- The purpose of the financing
- The authorized signatories and the
;persons of authority
3

 ( )

- The customers address, including his

phone numbers, mail address, the name
and location of the street, his e-mail and
fax number.
- The nature of the customers activities.
- The customers financial statements,
capital, sources of income and wealth, the
number of the branches of affiliated
establishments or companies, if any, and
their locations.

3.
Basic ongoing due diligence shall be
conducted on all customers and real
beneficiaries on a continuous basis to
verify the conformity of the business
relationship with the information provided
to the Company.
4.
The Company shall set in place risk
management systems to identify whether
the current, new (future) customer, or real
beneficiary has already occupied, is
currently occupying, or is expected to
occupy in the future a politically exposed
person. Also, it shall take proper measures
to identify source of wealth and source
funds of customers and real beneficiaries
who are identified as politically exposed
persons (PEPs) and shall classify them as
high-risk relationships, which require
approval of the senior management and
strict continuous follow up of business
relationships with them.
5. Additional due diligence shall be
awarded to all high risk business
relationships and operations that shall
be monitored on a continuous basis.
The approval of the senior management
shall also be obtained at the beginning
or renewal of the business relationship
while taking into account the following
factors:
a) The geographical location of the

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12

12
(
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11

operations, the beneficiary and the

place of business.
b) The nature of the operations and
services requested by the customer.
c) Any further information that may
indicate that the customer represents a
high risk such as politically exposed
persons (PEPs) or the customers are
located in countries that do not or
insufficiently
apply
the
FATF
recommendations.
6. When the Company discovers that the
existing or new (future) customer or
real beneficiary was/is occupying a
politically exposed post, it shall obtain
approval of the senior management to
continue the business relationships with
him/her.
7. Companies shall perform enhanced due
diligence for high-risk customers,
business relationships or transactions.
8. It is prohibited to deal with new
customers unless they appear before the
Company and meet the officials in
person. This includes the applications
submitted through the post, internet and
phone, except for those submitted by a
valid power of attorney providing for an
official authorization to perform all
measures of financing and loan taking.
The power of attorney must include all
personal particulars of both the
customer and real beneficiary.
9. The Company shall monitor business
relationships with its customers on a
continuous basis and verify the
accuracy of the information obtained
about the customer.
10.The Company shall verify the names of
customers
or
real
beneficiaries
(individuals,
establishments
or
companies) whose transactions shall be
11

reported or with whom transactions are

prohibited according to the lists
published by SAMA or the UN, before
starting the transactions with them or
upon
establishing
the
business
relationships.
11.In case the name of a customer or real
beneficiary is mentioned on any list
issued by SAMA or the UN, the
Company shall enforce the instructions
relating to how to of deal with the
customer, which may require the
freezing of transactions, the notification
of the appropriate authorities and
providing them with all information
relating to the transaction or the
customer. The company is not allowed
to suspend the freezing lift without
SAMAs instructions. The Company is
required to immediately comply with
SAMAs instructions in this regard.
12. The Company shall refer to the UN
lists of CFT and continually update
those lists from the following website:
http://www.un.org/sc/committees/1267/con
solist.shtml
13. The Company shall keep in its records
updated lists of all the persons with
whom transactions are prohibited and
whose names are provided to it by
SAMA.
14. The Company shall monitor sanctions
lists issued by other countries and
verify all transactions and compare
them with these lists in order to avoid
any potential legal problems that the
company may confront with its
customers, companies or financial
institutions in other countries, and also
to avoid the freezing of customers
transactions.
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:
http://www.un.org/sc/committees/12
67/consolist.shtml
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2

3

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Third: When Customer Due Diligence is

Required:

The cases that require CDD measures by

the Company against a customer are:
Upon initiating a business relationship.
Suspicion of a ML or TF transaction.
Suspicion of the accuracy of data,
information or documents obtained
from the customer.

Fourth: Third Parties and mediators:

a. It shall not be permissible to depend on
a third party to meet Due Diligence
measures for customers residing in the
Kingdom.
b. In certain cases where a business
relationship is entered into with nonresidents in the Kingdom after
obtaining no-objection from SAMA
regarding the establishment of such
relationship. The company shall ensure
that the third party applies sufficient
Due Diligence measures to such
customers. The company shall also
obtain an undertaking from the third
party to promptly provide the company
and supervisory authorities in the
Kingdom with any information about
customers, if requested.
c. In case of depending on a third party to
meet Due Diligence measures, the
company shall ensure that the third
party is subject to regulation and
control.
d. The Ultimate responsibility for
indentifying and verifying customers
identity shall remain with the company
that depends on a third party.

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4- Complex and Unusual Transactions:

The Company shall pay special attention
to all complicated, large and unusual
transactions that do not have an obvious
economic or normal purpose. The
company shall also obtain complete
information on the purpose of these
operations and transactions, and check
them to the maximum extent as possible,
and document them in writing. It shall
make such results available to
supervisory authorities upon request,
and maintain their records for ten years
as a minimum.

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5- Documents and Records Keeping:

1. The company, in line with its internal
measures, shall retain all records and
documents related to transactions, ID
particulars and correspondence of the
customer or the real beneficiary for at
least ten years as a minimum from the
ending date of the transaction or the
relationship with the customer or the
real beneficiary. The company shall be
committed to keep documents for a
longer period if requested by the
authorities concerned with AML/CFT
in the Kingdom.
2. The Company shall keep records that
enable appropriate authorities to keep
track of transactions and reconstruct
them.
3. The Company shall obtain SAMAs
prior approval to provide any local or
foreign authorities, at their request,
with documents or information about
its customers, real beneficiaries or their
transactions.
4. The Company shall establish written
14

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.3

.4

.5

.6

.7

policies and measures to be applied by

its employees when providing local or
foreign authorities with information
and documents upon their request,
subject to all relevant laws and rules.
5. The Company shall provide through
SAMA in a timely manner, copies of
the records and information relating to
the customer / real beneficiary and his
operations
to:
the
Financial
Investigation Unit (FIU) of the
Ministry of Interior, investigation
authorities and the judicial authorities
concerned with AML/CFT, at their
requests.
6. The Company shall update the data,
records and documents that are
obtained as per CDD measures in order
to verify their accuracy and validity.
The Company is required to review
such documents on a continuous basis.
[

6- Monitoring Transactions:
1. The Company shall conduct continuous
monitoring of the activities of its
customers and apply prescribed
procedures in order to identify all
complex, unusual, large transactions
and suspicious transactions that do not
have an obvious normal purpose and
document them in writing.
2. The company shall establish adequate
electronic and non-electronic systems
that help in monitoring operations and
tracking of suspicious transactions.
3. The Company shall pay further
attention to complex or unusual large
transactions characterized by a pattern
different of usual operations or do not
have an acceptable purpose or a clear
economic or normal reason.
15



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1

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2

4. The monitoring process of customers

transactions shall be on a relative
importance and risk basis.
5. The Company shall, on a continuous
basis, conduct CDD measures on all
existing customers, reconcile their
information with their transactions, and
reclassify customers on a relative
importance and risk basis through
linking customers data with their
transactions.
6. The Company shall establish adequate
policies and measures to identify high
risk customers, monitor and review
their activities on a continuous basis,
and obtain the senior managements
approval when starting to deal and redeal with them. The Company shall also
put in place key indicators to assist it in
identifying those customers, according
to the customers country of origin,
customers type, sources of income and
type of operations,etc. The senior
management shall pay high attention to
administrative information systems and
high risk personal financing activities.
7. The Company shall not only rely on
computer applications when monitoring
operations; the company shall link
transactions with customers data.
7- Reporting of Customers and
Suspicious Transactions:
1. The Company shall promptly report any
transactions suspected to be connected
to Money Laundering (ML) or
Terrorism Financing (TF), including
reporting attempts to perform such
transactions of regardless of thier
amount, to the FIU at the Ministry of
Interior, according to the reporting form
attached herein (enclosure 2).
16

2. The Company shall appoint a

compliance officer specialized in
combating ML/TF operations whose
duties includes reporting and followingup suspicious transactions.
3. The Company shall establish and adopt
written internal policies and measures
clarifying
the
mechanisms
and
measures to be followed by its
employees, including the compliance
officer concerned with combating
ML/FT, to report to the authorities
concerned upon suspecting any
operation. The Company shall inform
all its employees of this mechanism and
insure their compliance therewith.
4. The Company shall make available
copies of all the documents, data, and
files of the persons related to the
suspicious transaction and provide them
to the FIU at the Ministry of Interior.
5. The appropriate unit or the AML/CFT
compliance officer shall prepare an
annual report and submit it to the
Companys
senior
management,
including suspicious transactions and
all reported cases, the measures taken in
this regard, the developments thereof
and any proposals made to enhance the
efficiency and effectiveness of the
Companys measures, policies and
internal controls. He shall also provide
a copy thereof to SAMA.
6. The Company shall not alarm or inform
its customers or any party connected to
suspicious transactions or reported to
the FIU.
7. Alarming or assisting any person
connected with ML/TF operations or
failing to report thereof may expose the
company and its employees to legal and
financial liability. The Company and its
17

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.1

.3

.4

reporting employees shall be relieved

from any responsibility due to their
reporting to FIU, whether the suspicion
notifications were proven to be true or
not as long as the reporting was done in
good faith.
8- Internal Control Requirements and
Procedures
First General Requirements:
1. The Company shall establish policies,
measures and internal controls that
contribute to combating ML/TF and
inform all of its employees thereof.
2. The Company shall establish policies
and take necessary measures to prevent
the abuse of modern communication
and electronic systems for ML/TF
purposes.
3. The Company shall not provide its
services to any customer through
electronic means such as the internet
unless there is a close business
relationship authenticated with the
Company and after obtaining and
verifying his identity by meeting him in
person (face to face).
Second Internal Control Procedures:
1. Internal control programs in the
Company shall comprise auditing and
internal control systems that verify the
availability of essential AML/CFT
requirements. The Company shall
develop and enforce policies, plans and
internal measures, including the
appointment of highly competent
employees at the level of senior
management to apply such measures. It
shall
also
establish
adequate
recruitment criteria that ensure the
18

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selection of its employees from persons

of high competence and integrity. The
Board of directors or the person
delegated by him shall be in charge
thereof.
The internal audit department in
companies shall conduct regular
evaluation processes to verify the
effectiveness of AML/CFT policies,
measures and internal controls and
ensure compliance therewith.
The external auditor shall, in addition to
his usual functions, verify the
compliance of the Company with
AML/CFT policies.
The Company shall provide the
necessary and sufficient financial and
human resources for internal control
functions in the AML/CFT field.
The Company shall create a special unit
or appoint a compliance officer
specialized in combating ML/TF and
provide it/him with the following:
total independence from the other
departments of the Company with a
direct reporting line to the senior
management.
the power to have access to all
operations and customers data on a
timely basis.
adequate technological and human
capacities that help in performing the
functions appropriately.
The functions of the said unit or the
AML/CFT compliance officer shall
include the following:

2.

3.

4.

5.

6.

a) Verifying that written and effective

policies and procedures are established

and that they prevent the misuse of the
- Company in ML/TF operations. These
13

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:

( )

policies shall include indicators that

assist in discovering such transactions.
The policies shall be updated on a
periodical basis and in keeping with
developments.
b) Establishing AML/CFT policies and
procedures and ensuring that they are
adequate, as a minimum, with relevant
regulatory requirements.
c) Establishing and developing the
appropriate mechanism that ensures
compliance with all instructions,
regulations and internal control
measures.
Establishing
internal
precautionary control procedures to
detect any activity related to ML/TF or
any violations thereof.
d) Review AML policies and procedures
on a regular basis to ensure their
effectiveness and take necessary
measures to identify any changes
therein and the their effect on the
procedures followed in the Company.
e) Establishing and applying ethical
criteria and high professional rules to be
complied with by all employees to
prevent the misuse of the Company,
whether
intentionally
or
unintentionally, for criminal purposes.
9- Cooperation:
1. The
Company
shall
promote
cooperation mechanisms with similar
companies and various competent
authorities, directly or indirectly, in order
to combat ML/TF and exchange and
share relevant information. However, at
the same time, the company must strictly
comply with regulatory procedures aimed
to protect customers information
confidentiality and transactions. Prior
SAMA guidance should be obtained if
22

companies agree to mutually cooperate or

exchange relevant information.
2. The Company shall have in place
appropriate policies and procedures, as
follows:
Determining the manner and the
method to be followed by the Company
when contacting appropriate entities for
passing relevant information to them on
such transactions.
Determining records (original or
copies) and the receipts and forms to be
used for providing and receiving
information by the Company in case
that records should be provided to
appropriate entities.
When information is to be provided
verbally to appropriate entities, the
manner and the forms to be used should
be determined.
A prior approval of SAMA shall be
required for sharing information with
any foreign entities.
10- Training of Employees:
1. The Company shall prepare and
organize regular training programs for
its employees in order to enhance their
awareness of the AML/CFT regulations
and rules and their understanding of
such operations, their different patterns
and the internal instructions to combat
them, including identifying suspicious
operations, reporting measures as well
as customer identification and due
diligence procedures and keeping
employees abreast of the latest
developments in that field.
2. The Company shall have in place
training programs for new employees,
particularly for those dealing directly
with the public.
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3. The company shall ensure that the

training programs offered to its
employees include the mechanisms of
verifying ID validity and particulars,
documenting the copy cross-checked
with the original.
4. The Company shall update the training
programs occasionally, according to the
latest developments in that field.
5. The Company shall put in place plans,
programs and proper budgets especially
allocated to the training of its
employees in the AML/CFT field.

ANNEXES

)1(

Annex No. 1

ML/TF Indicators:
The indicators listed below aim at
raising the awareness of the
Companys
employees
regarding
ML/TF operations and any financial
activities associated therewith and at
assisting them in detecting any ML/TF
operation. In case there is one or
several indicator(s), this means that
suspicions exist about a specific
operation and that an accurate
investigation is required about a
ML/TF operation.
The following indicators were defined
as guidelines and the Company shall
revise them and add new ones if it
deems there are reasonable reasons.

22

1. Indicators at the beginning of

any financing transaction:
Review of the transactions data,
in case the transaction was
unusually good for the customer or
inappropriate to his activity or
financial status.
Inconsistency of the transaction
with the volume of the customer's
businesses.
Probability
of
disagreement
between the customer and the
Company.
Is the financed asset connected to
the customers nature of work and
need.
Possibility of exaggeration in the
value of the financed asset.
Probability of non-existence of the
financed asset.
A large increase in the number of
the customers transactions with
the Company.
Request of credit facilities against
of guarantees issued by a bank
operating outside the KSA.
Reluctance of the customer to
provide data about the source of
his funds or attempt to provide the
Company
with
misleading
information.
The Company's knowledge that the
customer is involved in ML/TF
operations or in any criminal or
regulatory offences.
The customer is unable to give a
description of the nature of his
business or is unaware of the
activities he performs in general.
Refusal of another financial
institution to start or maintain a
business relationship with the

: .1

: .2

23

.3 :

( )

24

same customer.
Noting the existence of large cash
transactions for the customer when
reviewing his bank statements.
2. Indicators after the beginning of
financing transactions:
Cases of annulment or early
settlement of financing contracts.
Requests by the customer for
transferring financing contracts to
another customer.
In case financing installments are
paid on a continual basis and in
large amounts exceeding the limit
agreed upon.
In case the amount of financing
installments is paid through
cheques issued by other persons or
parties.
The customer attempts to pay
financial obligations in cash
contrary to other usual payment
means.
The customers obligations exceed
his apperent or usual financial
capabilities.
The customer pays his financial
obligations through the accounts
he owns in banks operating outside
the Kingdom.
Use of the credit facilities granted
to the customer for purposes other
than those stated upon submission
of the request.
The customer pays an unusual
attention to compliance with the
AML/CFT requirements.
The customer shows excessive
indifference
to
risks
and
commissions
or
any
other
expenditure.
The customer's attempts to change

or cancel a deal, after being

informed of the requirements of
information verification or record
keeping by the Company.
The customer's request for the
termination of the procedures of a
deal in which he uses the
minimum possible amount of
documents.
3. Indicators about the Companys
Employees:
The employee is having living
conditions inconsistent with the
salary he receives from the
Company
The employee's continuous work
for a long time without taking any
leaves
The employee's attempts to
facilitate the provision of the
Companys services to a customer
(a natural or legal person),
ignoring the application of usual
procedures.

25

()2

14 / / :

()

222 / / :

(: )

26

Annex n (2)
(Confidential)
Reporting of a suspicious financial transaction
Ref:
Date: / /14AH
Corresponding to: / /20AD
Attachments:
Information about the reporting party
Financial
Institutions
Non financial
institutions
Contact of the
reporting party
Type of the
transaction

Date of execution

Name

City

Branch

Phone

Name of the party

City

Branch

Phone

Name:

Phone:

Deposit
Cheque
Cash
Time

Amount

Others

Month
In letters

Account Number

Transactions
operator
Grounds of
Suspicion
Name

Content of the Report

Withdrawal
Bank
Transfer
Branch
Local
ATM
Foreign
Day
Date

In numbers

Account of the
transactions
operator

Address:

Name

ID Card No,

Account Number

Year
Currency

Branch No.

ID Card Number

The Beneficiary
Nationality
Branch No.

State

Nationality

City

Bank of the Beneficiary

Your Excellency, the Director of the Financial Investigations Directorate

You may find above our notification of a suspicious financial transaction for your
information and appropriate action as you deem necessary.
Post::

Official Seal:

N.B.: (Any additional information shall be sent in a separate paper)

27